BarbriSFCourseDetails

Course Details

This CLE course will discuss the SEC's June 5, 2019 adoption of Regulation Best Interest, Form CRS and other rules and interpretations, and their effect on registered investment advisers, registered broker-dealers and investment companies.

Description

Lawrence P. Stadulis, Sara P. Crovitz and John M. Baker, members of Stradley Ronon’s Fiduciary Governance Group, will explain the practical implications for broker-dealers, investment advisers and investment companies on the Securities and Exchange Commission’s (SEC) new standard of conduct rules and guidance. Specifically, they will discuss:

  • Regulation Best Interest: How and why the SEC adopted, and the implications for firms of, a standard of conduct for broker-dealers and their associated natural persons when making a recommendation to a retail customer of any securities transaction or investment strategy involving securities.
  • Form CRS: How and why the SEC adopted, and the implications for firms of, a requirement for registered investment advisers and registered broker-dealers to provide a Form CRS relationship summary to retail investors.
  • Standard of Conduct for Investment Advisers: How and why the SEC adopted, and the implications for firms of, an interpretation of the standard of conduct for investment advisers.
  • “Solely Incidental”: How and why the SEC adopted, and the implications for firms of, an interpretation of the “solely incidental” prong of section 202(a)(11)(C) of the Investment Advisers Act of 1940, which provides that the term “investment adviser” does not include any broker or dealer whose performance of investment advisory services is solely incidental to the conduct of his business as a broker or dealer and who receives no special compensation therefor.

Benefits

The panel will review these and other critical issues:

  • How does Regulation Best Interest differ from the existing federal suitability standard applicable to broker-dealers?
  • What specific obligations are imposed on broker-dealers under Regulation Best Interest?
  • How do they differ from those applicable to registered investment advisers?
  • What are some key practical steps that broker-dealers can take to ensure compliance with Regulation BI and applicable state law broker-dealer conduct standards”?
  • How does the interpretive guidance regarding the standard of conduct for investment advisers impact advisers, particularly advisers to investment companies?
  • What information is required in Form CRS?